Which regulations, laws and good practices were used to build these tools?
Seven sources, reviewed article by article. FIVE are legally binding in Costa Rica: Ley 7786 and its regulation, Decreto Ejecutivo 36948, which define who is a regulated entity and what their duties are; Acuerdo CONASSIF 12-21, which governs the entities of article 14; Acuerdo CONASSIF 11-21, which sets the closed catalogue of source-of-funds evidence and the use of the CICAC; and Acuerdo SUGEF 13-19, which governs those registered under articles 15 and 15 bis. The other TWO are good practice and not Costa Rican regulatory requirements: the INTE/ISO 37301:2021 compliance management systems standard, which is where the controls over outsourced processes, the monitoring and the internal audit come from; and the OECD Due Diligence Guidance, which is where the six-stage third-party model comes from. Every rule in the package names the article that supports it, so it can be verified at source.
Which entities does this matrix apply to?
If you are a regulated entity under article 14 of Ley 7786 — supervised by SUGEF, SUGEVAL, SUGESE or SUPEN — the Acuerdo CONASSIF 12-21 regime applies. If you are registered under articles 15 or 15 bis, Acuerdo SUGEF 13-19 applies. The matrix covers both regimes and its parameters sheet compares them side by side.
Does it replace our internal policy?
No. It is a complete, traceable base to build or review one. The parameters that Acuerdo CONASSIF 12-21 leaves to the entity's judgement — frequencies, alerts, exemptions — have to be decided and motivated in minutes, and one of the templates exists exactly for that.
Why does a bank statement not count as source of funds?
Because Acuerdo CONASSIF 11-21, in its Section II, expressly excludes it. A bank statement shows movements, not the source that generates them. The package includes the full catalogue of what is accepted, with each item's maximum age, and a plain-language page to explain it to the client.
How often does a client have to be updated?
Under Acuerdo CONASSIF 12-21 each entity's own policy decides, based on risk, with a ceiling of sixty months and a higher frequency for high risk. Under Acuerdo SUGEF 13-19 the deadlines are fixed. Many policies still copy the fixed deadlines with no minutes to justify them, and that is a finding however reasonable the deadlines are.
Can I accept the RTBF declaration instead of the notarised capital certificate?
Yes, under article 34 of Acuerdo CONASSIF 12-21, stamped by the Central Bank and issued no more than thirty days earlier. It is free, and most entities still do not accept it.
Are the templates editable?
The tools are: Word, Excel and PowerPoint, with no macros. The guides and the presentation are PDF on purpose, because they are reference material and are not built to be altered.
Is it useful if my entity already has an approved policy?
Yes, and that is the most common use. The matrix lets you check your current policy rule by rule against the regulation, and the pre-supervision self-assessment — thirty questions with the evidence expected for each — shows where the support is missing before the supervisor finds it.
Is it up to date?
The package was prepared on Costa Rican regulation in force as of September 2026, and includes a version and regulatory change log to record every review. Regulation changes: the cut-off date is written into every file.